Assessee is  a tax resident of UK and was awarded contract from ONGC along with four other consortium members whereby assessee was required to manufacture and supply subsea production system components. Assessing Officer treated contract as a composite contract and vide draft order held that consortium member was working on behalf of assessee-company which forms PE of assessee-company and further held that assessee is  also involved in survey, installation and commissioning of equipment in India and since payments were not bifurcable, entire receipts of assessee were taxable in India under section 44BB  of the Act. DRP is held that off shore supplies were also within the ambit of section 44BB of the Act. Held that  burden of proving existence of PE had not been discharged by revenue and thus, there being no finding of PE in instant case, section 44BB would not apply. (AY. 2020-21)